Template Version: 1.4

Date: May 2021

Prepared for: USDA OCIO-Policy, 

E-Government and Fair Information 

Practices (PE&F)

Policy, E-Government and Fair Information Practices

Privacy Impact Assessment 

Marketing and Regulatory Programs (MRP)

Animal and Plant Health Inspection Service (APHIS)

Integrated Plant Health Information System 

(IPHIS)
Privacy Impact Assessment – MRP APHIS IPHIS

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Privacy Impact Assessment for the

Integrated Plant Health Information 

System (IPHIS)

May 2021

Contact:

Steven King

MRP APHIS IT

301-851-2118

Reviewing Official:

Tonya Woods

APHIS Privacy Act Officer

United States Department of Agriculture

(301) 851-4076
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Abstract 

System name: Marketing and Regulatory Programs (MRP), Animal and Plant Health 

Inspection Service (APHIS), Integrated Plant Health Information System (IPHIS). 

IPHIS provides a Web-based plant health data management system for use by all levels of 

plant health personnel within the Agency (e.g., executives, managers, and field personnel), as 

well as cooperators outside the Agency (e.g., diagnostic laboratories, state and local 

governments, and academia). 

This document has been completed in accordance with the requirements of the E-Government 

Act of 2002.

Overview 

IPHIS is a Plant Protection and Quarantine Investment in the Animal and Plant Health

Inspection Service portfolio. IPHIS provides users with an electronic interface to access,

enter, and view data for plant health events nationwide. The following data is contained and 

provided to IPHIS users: results of plant pest, noxious weed, and biocontrol surveys to

include: survey locations, target pests, survey sample identification, and diagnostic test

results; survey supply orders and inventory management; domestic emergency action 

notifications; and compliance agreements and inspections. Any information sharing conducted 

by the program or system information shared may include but is not limited to pest name, 

absence or presence, crop/host, location, and environment in which a crop/host is found or 

surveyed, survey methods, and frequency and scope of a survey. IPHIS is operating under an

Authority to Operate issued by the MRP Authorizing Official.

Section 1.0 Characterization of the Information 

The following questions are intended to define the scope of the information requested and/or 

collected as well as reasons for its collection as part of the program, system, rule, or technology 

being developed. 

1.1 What information is collected, used, disseminated, or maintained in 

the system? 

Plant pest, noxious weed, and biocontrol survey data including pest/weed names, 

source of data, specific crop/host, location and environment in which a crop/host is 

found or surveyed, survey method (visual or survey device), survey location, pest 

absence/presence, plant health events, diagnostic results including sample ID and 

confirmation method, survey supply orders and inventory management, regulatory 

action notifications, and tracking and control documentation. The system also collects 

information related to business entities and individuals such as name, address, 

telephone number, fax number, email address, and Longitude/Latitude. The system 
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also includes information, such as names, addresses, email addresses, and phone and 

fax numbers, about APHIS employees and contractors or others working on behalf of 

APHIS.

1.2 What are the sources of the information in the system? 

Data is derived from the following sources: USDA APHIS employees, such as APHIS 

PPQ field specialists, identifiers, and other personnel and their supervisors, other 

Federal Agencies, State, Tribal, and local government Agencies, individuals, and 

University cooperators, regulated individuals and entities, and diagnostic laboratories.

1.3 Why is the information being collected, used, disseminated, or 

maintained? 

The information is collected, used, disseminated, or maintained for the purpose of 

preparing, monitoring, and responding to plant health related issues to protect 

American agriculture. This is accomplished by: the early detection and tracking of 

exotic and invasive plant pests and noxious weeds to prevent spread; facilitating the 

export and interstate movement of agricultural products by monitoring the occurrence 

and distribution of certain organisms; issuing compliance agreements for the 

interstate movement of regulated articles; facilitating pest management by monitoring 

the occurrence and distribution of pests and beneficial organisms; communicating the 

activities and results of survey detection to cooperators and/or users on a timely basis; 

responding to plant health pest outbreaks; validating pest risk models; and forecasting 

surveys supply needs. 

1.4 How is the information collected? 

Information is collected by use of paper/excel spreadsheet template, and pencil/pen, or 

in electronic (i.e. PDA's, tablets, iPads, etc.) formatted by APHIS and/or its cooperators. 

1.5 How will the information be checked for accuracy? 

Automated referential integrity checks and business rules will be performed on the 

data as it is collected from the various identified sources. Additional referential 

integrity checks and business rules will be performed on the data before committing 

the data to the IPHIS database. Periodic manual data currency reviews will be 

performed by IPHIS subject matter experts to ensure data accuracy. 

1.6 What specific legal authorities, arrangements, and/or agreements 

defined the collection of information? 

Plant Protection Act (7 U.S.C. 7701 et seq.); The Honey Bee Act (7 U.S.C. 281 et 

seq.); the Food Conservation and Energy Act 2008 (7 U.S.C. 8791 et seq.); 
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Compliance Agreements; Emergency Action Notifications; and scientific survey 

methodology. 

1.7 Privacy Impact Analysis: Given the amount and type of data 

collected, discuss the privacy risks identified and how they were 

mitigated. 

The privacy risks identified would be integrity and availability of the data. The risks 

are mitigated thru the use of 2-layer authentication. Integrated Network Authentication 

is required for access to the system. The role-based access control list for the database 

validates against the network identification of the user creating a 2-layer 

authentication schema. This controls who has access to the system. 

Section 2.0 Uses of the Information 

The following questions are intended to delineate clearly the use of information and the 

accuracy of the data being used. 

2.1 Describe all the uses of information. 

The principle use of the information is for preparation, monitoring and response to 

plant health related issues. The data will describe pest status and location to plant 

health responders, senior level federal and state policy makers. Specifically, the 

information will be used as an information tool to help determine what effective action 

must be taken when a plant pest or noxious weed is found. Additional uses of the 

information will be to facilitate the export and interstate movement of agricultural 

products; the issuance of compliance agreements for the interstate movement of 

regulated articles; to facilitate management of pests and beneficial organisms; to 

communicate the activities and results of survey detection to users on a timely basis; to 

monitor the distribution of pests; to respond to a plant health pest outbreak; to forecast 

survey supply needs; and to validate pest risk models. COGNOS extracts Plant pest, 

noxious weed, and bio-control survey data to generate reports that are used for Data 

analysis and program management decisions. County level summary data will be 

exported from IPHIS then uploaded into the National Agricultural Pest Information 

System (NAPIS), Purdue University, to support the web based public interface site 

Pest Tracker for the Cooperative Agricultural Pest Survey Program. 

2.2 What types of tools are used to analyze data and what type of data 

may be produced? 

The system uses COGNOS business intelligence software for generating reports 

regarding plant health data within the system.
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2.3 If the system uses commercial or publicly available data please 

explain why and how it is used. 

ESRI provides the street map and aerial photography that serve as a 

background/reference maps for the display of IPHIS data. ESRI also provides 

geographic coordinates when a location address is entered but the latitude and 

longitude data are missing. Open Street maps are used on the iOS Mobile data 

collector for mapping on the mobile devices. 

2.4 Privacy Impact Analysis: Describe any types of controls that may be 

in place to ensure that information is handled in accordance with the 

above described uses. 

Role based robust authentication and authorization via USDA eAuthentication; 

physical access control, firewalls (access control), intrusion detection systems, and 

system auditing are among the countermeasures used to prevent unauthorized access. 

Additionally, all cooperators authorized to access information have signed a General 

Memorandum of Understanding in which they have agreed to safeguard the 

confidentiality of such data and prohibit unauthorized access to the data provided by 

USDA MRP APHIS. They also agree not to release any of the data provided by 

USDA MRP APHIS, and to refer any and all requests for the data provided to USDA 

MRP APHIS Legislative and Public Affairs, Freedom of Information and Privacy Act 

Office.

Section 3.0 Retention 

The following questions are intended to outline how long information will be retained after the 

initial collection. 

3.1 How long is information retained? 

The data is to be retained in the database indefinitely pending NARA’s approval of a 

records retention schedule. 

3.2 Has the retention period been approved by the component records 

officer and the National Archives and Records Administration 

(NARA)? 

A retention period has not been formally established for data at this time. APHIS is 

working closely with the National Archives and Records Administration to update 

retention schedules. 

3.3 Privacy Impact Analysis: Please discuss the risks associated with the 

length of time data is retained and how those risks are mitigated. 
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No risks have been identified with the length of time for retention of the data. 

Section 4.0 Internal Sharing and Disclosure 

The following questions are intended to define the scope of sharing within the United States 

Department of Agriculture.

4.1 With which internal organization(s) is the information shared, what 

information is shared and for what purpose? 

Information shared may include but is not limited to pest name, absence or presence, 

crop/host, location, and environment in which a crop/host is found or surveyed, survey 

methods, and frequency and scope of a survey. USDA MRP APHIS, and sister 

agencies such as Agricultural Research Service, Forest Service, National Institute of 

Food and Agriculture, Natural Resources Conservation Services, Risk Management 

Association, and Farm Service Agency may use this information for pathway analysis, 

trade, risk analysis, science, and any other uses necessary to support or to enhance 

USDA program goals.

4.2 How is the information transmitted or disclosed? 

Information deemed necessary to share may be transmitted or disclosed by verbal 

communication, paper, or electronic means. 

4.3 Privacy Impact Analysis: Considering the extent of internal 

information sharing, discuss the privacy risks associated with the 

sharing and how they were mitigated. 

The system has built in granularity based on the level of access deemed appropriate by 

IPHIS Business System Manager and System owner. This level of access is based on 

individual needs without compromising the integrity or security of the data. 

Additionally, when any personally identifiable data is shared all personnel are advised 

of the rights provided individuals, agricultural producers, or owners of agricultural 

lands under the Privacy Act of 1974, the Freedom of Information Act, and The Food 

Conservation and Energy Act 2008 7 U.S.C. 8791. 

Section 5.0 External Sharing and Disclosure 

The following questions are intended to define the content, scope, and authority for 

information sharing external to USDA which includes Federal, state and local government, 

and the private sector. 

5.1 With which external organization(s) is the information shared, what 

information is shared, and for what purpose? 
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In addition to those disclosures generally permitted under 5 U.S.C. 552a(b) of 

the Privacy Act, records maintained in the system may be disclosed outside USDA, as 

follows: 

(1) To cooperators from other Federal departments and their agencies; State, 

Local, Tribal, and Territorial governments; plant health officials; cooperators from 

academic institutions; and diagnostic laboratories performing functions or working to 

respond to events declared to be emergencies of national significance determined to 

impact the U.S. critical infrastructure or other related emergency response functions 

performed for USDA, when necessary to accomplish an agency function related to this 

system of records;

(2) When a record on its face, or in conjunction with other records indicates a 

violation or potential violation of law, whether civil, criminal, or regulatory in nature, 

and whether arising by general statute or particular program, statute, or by regulation, 

rule, or order issued pursuant thereto, APHIS may disclose the record to the 

appropriate agency, whether Federal, foreign, State, Tribal, local, or other public 

authority responsible for enforcing, investigating, or prosecuting such violation or 

charged with enforcing or implementing the statute, rule, regulation, or order issued 

pursuant thereto, if the information disclosed is relevant to any enforcement, 

regulatory, investigative, or prosecutive responsibility of the receiving entity; 

(3) To the Department of Justice when: (a) USDA or any component thereof; 

or (b) any employee of USDA in his or her official capacity, or any employee of the 

agency in his or her individual capacity where the Department of Justice has agreed to 

represent the employee; or (c) the United States Government, is a party to litigation or 

has an interest in such litigation, and USDA determines that the records are relevant 

and necessary to the litigation and the use of such records by the Department of Justice 

is for a purpose that is compatible with the purpose for which USDA collected the 

records;

(4) In an appropriate proceeding before a court, grand jury, or administrative 

or adjudicative body or official, when the USDA or other Agency representing the 

USDA determines that the records are relevant and necessary to the proceeding; or in 

an appropriate proceeding before an administrative or adjudicative body when the 

adjudicator determines the records to be relevant to the proceeding;

(5) To appropriate agencies, entities, and persons when: (a) USDA suspects or 

has confirmed that there has been a breach of the system of records; (b) USDA has 

determined that as a result of the suspected or confirmed breach there is a risk of harm 

to individuals, USDA (including its information systems, programs, and operations), 

the Federal Government, or national security; and (c) the disclosure made to such 

agencies, entities, and persons is reasonably necessary to assist in connection with 

USDA’s efforts to respond to the suspected or confirmed compromise and prevent, 

minimize, or remedy such harm;

(6) To another Federal agency or Federal entity, when information from this 

system of records is reasonably necessary to assist the recipient agency or entity in (a) 

responding to a suspected or confirmed breach or (b) preventing, minimizing, or 
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remedying the risk of harm to individuals, the recipient agency or entity (including its 

information systems, programs, and operations), the Federal Government, or national 

security, resulting from a suspected or confirmed breach;

(7) To Congressional office staff in response to an inquiry made at the written 

request of the individual to whom the record pertains;

(8) To contractors and their agents, grantees, experts, consultants, and other 

performing or working on a contract, service, grant, cooperative agreement, or other 

assignment for the USDA, when necessary to accomplish an agency function related 

to this system of records; and

(9) To the National Archives and Records Administration or to the General 

Services Administration for records management activities conducted under 44 U.S.C. 

2904 and 2906.

5.2 Is the sharing of personally identifiable information outside the 

Department compatible with the original collection? If so, is it 

covered by an appropriate routine use in a SORN? If so, please 

describe. If not, please describe under what legal mechanism the 

program or system is allowed to share the personally identifiable 

information outside of USDA. 

Yes, personally identifiable information is shared. A SORN is being developed. This 

deficiency has been noted in POA&M number 28367. The personally identifiable 

information is being shared under the guidelines and authorities of the Plant Protection 

Act (7 U.S.C. 7701 et seq.); the Honey Bee Act (7 U.S.C. 281 et seq.); and the Food 

Conservation and Energy Act 2008 (7 U.S.C. 8791 et seq.). All cooperators that 

information is shared or exchange with have signed a General Memorandum of 

Understanding in which they have agreed to safeguard the confidentiality of such data 

and prohibit unauthorized access to the data provided by USDA MRP APHIS. They 

also agree not to release any of the data provided by USDA MRP APHIS, and to refer 

any and all requests for the data provided to USDA MRP APHIS Legislative and 

Public Affairs, Freedom of Information and Privacy Act Office. 

5.3 How is the information shared outside the Department and what 

security measures safeguard its transmission? 

Information may be shared by electronic means, verbally, and in paper format, and is 

determined by secure role-based data access. Any personally identifiable information 

shared is done under the guidelines and authorities of the Plant Protection Act 7 

U.S.C. 7701 et seq., and the Food Conservation and Energy Act of 2008 7 U.S.C. 

8791. All cooperators/collaborators that information is shared or exchange with have 

signed a General Memorandum of Understanding in which they have agreed to 

safeguard the confidentiality of such data and prohibit unauthorized access to the data 

provided by USDA MRP APHIS. They also agree not to release any of the data 

provided by USDA MRP APHIS, and to refer any and all requests for the data 
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provided to USDA MRP APHIS Legislative and Public Affairs, Freedom of 

Information and Privacy Act Office. 

5.4 Privacy Impact Analysis: Given the external sharing, explain the 

privacy risks identified and describe how they were mitigated. 

The privacy risks identified are the further disclosure of 1) information pertaining to 

specific locations and environment in which a crop/host is found or surveyed, and 2) 

points of contact and information provided by an agricultural producer or owner of 

agricultural land, concerning the agricultural operation, farming, or conservation 

practice, or of the land itself. Personally identifiable information is shared by following 

the guidelines and authorities of the Plant Protection Act (7 U.S.C. 7701 et seq.); The 

Honey Bee Act (7 U.S.C. 281 et seq.); and the Food Conservation and Energy Act 2008 

(7 U.S.C. 8791 et seq.). Additionally, all cooperators/collaborators that information is 

shared or exchange with have signed a General Memorandum of Understanding in 

which they have agreed to safeguard the confidentiality of such data and prohibit 

unauthorized access to the data provided by USDA MRP APHIS. They also agree not 

to release any of the data provided by USDA MRP APHIS, and to refer any and all 

requests for the data provided to USDA MRP APHIS Legislative and Public Affairs, 

Freedom of Information and Privacy Act Office. 

Section 6.0 Notice 

The following questions are directed at notice to the individual of the scope of information 

collected, the right to consent to uses of said information, and the right to decline to provide 

information. 

6.1 Does this system require a SORN and if so, please provide SORN 

name and URL.

Yes, and a SORN is being developed. 

6.2 Was notice provided to the individual prior to collection of 

information? 

Yes

6.3 Do individuals have the opportunity and/or right to decline to provide 

information? 

Yes

6.4 Do individuals have the right to consent to particular uses of the 

information? If so, how does the individual exercise the right? 
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No, if they consent to provide info.

6.5 Privacy Impact Analysis: Describe how notice is provided to 

individuals, and how the risks associated with individuals being 

unaware of the collection are mitigated. 

Notification is either verbally from USDA personnel in official uniform or by written 

notification in the form of flyers or written notices left at the property to be surveyed. 

There is no risk because individuals are always notified. Individuals can request their 

information using the procedures below in section 7.1. 

Section 7.0 Access, Redress and Correction 

The following questions are directed at an individual’s ability to ensure the accuracy of the 

information collected about them. 

7.1 What are the procedures that allow individuals to gain access to their 

information? 

All requests for access to records must be in writing and should be submitted to the 

APHIS Privacy Act Officer, 4700 River Road Unit 50, Riverdale, MD 20737; or by 

facsimile (301) 734-5941; or by email APHISPrivacy@usda.gov. In accordance with 

7 CFR part 1, subpart G, § 1.112 (Procedures for requests pertaining to individual 

records in a record system), the request must include the full name of the individual 

making the request; the name of the system of records; and preference of inspection, in 

person or by mail. In accordance with 7 CFR 1.113, prior to inspection of the records, 

the requester shall present sufficient identification to establish that the requester is the 

individual to whom the records pertain. In addition, if an individual submitting a 

request for access wishes to be supplied with copies of the records by mail, the 

requester must include with his or her request sufficient data for the agency to verify 

the requester's identity. 

7.2 What are the procedures for correcting inaccurate or erroneous 

information? 

Any individual may contest information contained within a record in the system that 

pertains to him/her by submitting a written request to the system manager at the 

address above. Include the reason for contesting the record and the proposed 

amendment to the information with supporting documentation to show how the record 

is inaccurate.
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7.3 How are individuals notified of the procedures for correcting their 

information? 

Publication of the System of Records Notification (SORN) provides information on 

access and amending information collected in IPHIS. The agency also provides the 

public with information via publicly accessible websites. For example, the Privacy Act

can be accessed at the following web address USDA APHIS | Privacy Act. 

7.4 If no formal redress is provided, what alternatives are available to the 

individual? 

N/A

7.5 Privacy Impact Analysis: Please discuss the privacy risks associated 

with the redress available to individuals and how those risks are 

mitigated. 

There are no privacy risks because redress is done according to guidelines set forth by 

the Freedom of Information and Privacy Act Staff.

Section 8.0 Technical Access and Security 

The following questions are intended to describe technical safeguards and security measures. 

8.1 What procedures are in place to determine which users may access 

the system and are they documented? 

Role based access controls and personnel security policies will be implemented and 

followed as part of the baseline security requirements. Moreover, a position sensitivity 

matrix will be developed and continually maintained to determine whether access is 

required and the appropriate level of access if it is deemed necessary.

8.2 Will Department contractors have access to the system? 

Yes.

8.3 Describe what privacy training is provided to users either generally 

or specifically relevant to the program or system? 

All APHIS personnel and contractors are required to complete the USDA Information 

Security Awareness Training & Acknowledgment of Rules of Behavior.
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8.4 Has Certification & Accreditation been completed for the system or 

systems supporting the program? 

Yes.

8.5 What auditing measures and technical safeguards are in place to 

prevent misuse of data? 

Authentication and authorization via USDA eAuth, physical access control, firewalls 

(access control), intrusion detection systems and system auditing are among the 

countermeasures used to prevent unauthorized access and misuse of data.

8.6 Privacy Impact Analysis: Given the sensitivity and scope of the 

information collected, as well as any information sharing conducted 

on the system, what privacy risks were identified and how do the 

security controls mitigate them? 

The privacy risks identified are the further disclosure of information pertaining to 

specific locations and environment in which a crop/host is found or surveyed, and 

points of contact and the information provided by an agricultural producer or owner of 

agricultural land, concerning the agricultural operation, farming, or conservation 

practices, or of the land itself. Personally identifiable information is shared by 

following the guidelines and authorities of the Plant Protection Act (7 U.S.C. 7701 et 

seq.); The Honey Bee Act (7 U.S.C. 281 et seq.); and the Food Conservation and 

Energy Act 2008 (7 U.S.C. 8791 et seq.). Additionally, all cooperators/collaborators 

that information is shared or exchange with have signed a General Memorandum of 

Understanding in which they have agreed to safeguard the confidentiality of such data 

and prohibit unauthorized access to the data provided by USDA APHIS. The

cooperators/collaborators also agree not to release any of the data provided by USDA 

MRP APHIS, and to refer any and all requests for the data provided to USDA MRP 

APHIS Legislative and Public Affairs, Freedom of Information and Privacy Act 

Office.

Section 9.0 Technology 

The following questions are directed at critically analyzing the selection process for any 

technologies utilized by the system, including system hardware and other technology. 

9.1 What type of project is the program or system? 

Web-based plant health data management system with mobile data collectors.
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9.2 Does the project employ technology which may raise privacy 

concerns? If so, please discuss their implementation. 

The project does not employ any technology that would raise privacy concerns.

Section 10.0 Third Party Websites/Applications 

The following questions are directed at critically analyzing the privacy impact of using third 

party websites and/or applications.

10.1 Has the System Owner (SO) and/or Information Systems Security 

Program Manager (ISSPM) reviewed Office of Management and 

Budget (OMB) memorandums M-10-22 “Guidance for Online Use of 

Web Measurement and Customization Technology” and M-10-23 

“Guidance for Agency Use of Third-Party Websites and 

Applications”?

Yes.

10.2 What is the specific purpose of the agency’s use of 3rd party websites 

and/or applications?

The 3rd party website is used to provide Mapping service data such as Base maps, which 

provides world topography, street demographic, and reference overlay information that is 

available in public domain: https://unpkg.com/leaflet@2.1.3/dist/leaflet.js

10.3 What personally identifiable information (PII) will become available 

through the agency’s use of 3rd party websites and/or applications.

No PII data would become available because of the use of 3rd party website.

10.4 How will the PII that becomes available through the agency’s use of 

3rd party websites and/or applications be used?

N/A

10.5 How will the PII that becomes available through the agency’s use of 

3rd party websites and/or applications be maintained and secured?

N/A
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10.6 Is the PII that becomes available through the agency’s use of 3rd party 

websites and/or applications purged periodically? 

N/A

10.7 Who will have access to PII that becomes available through the 

agency’s use of 3rd party websites and/or applications?

N/A

10.8 With whom will the PII that becomes available through the agency’s 

use of 3rd party websites and/or applications be shared - either 

internally or externally?

N/A

10.9 Will the activities involving the PII that becomes available through 

the agency’s use of 3rd party websites and/or applications require 

either the creation or modification of a system of records notice 

(SORN)?

N/A

10.10 Does the system use web measurement and customization technology?

No

10.11 Does the system allow users to either decline to opt-in or decide to 

opt-out of all uses of web measurement and customization 

technology?

System does not use web measurement or customization technology.

10.12 Privacy Impact Analysis: Given the amount and type of PII that 

becomes available through the agency’s use of 3rd party websites 

and/or applications, discuss the privacy risks identified and how they 

were mitigated. 

N/A
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Approval Signature 

________________________________ 

Aaron Alexander

Assistant Chief Information Security Officer (ACISO) 

MRP Information Technology Services

United States Department of Agriculture

________________________________ 

Tonya G. Woods 

Privacy Act Officer 

MRP Animal and Plant Health Inspection Service 

United States Department of Agriculture

________________________________ 

William M. Newton

IPHIS System Owner 

MRP Animal and Plant Health Inspection Service

United States Department of Agriculture